125 11. Legislation-related activities of the NPM Pursuant to Article 19 of the OPCAT, the NPM shall be granted power to submit “proposals and observations” concerning “existing or draft legislation”. 11.1. Legislative proposals concerning the operation of the NPM Based on the recommendation made by the Subcommittee, I reviewed the laws governing the operation of the NPM.244 The responsibilities and competence of the Commissioner for Fundamental Rights are regulated by Article 30 of the Fundamental Law of Hungary, as well as Act CXI of 2011 on the Commissioner for Fundamental Rights. Since I have no right to initiate acts either as the defender of fundamental rights or as the entity responsible for performing the tasks of the National Preventive Mechanism,245 I requested the assistance of the Minister of Justice as the member of government responsible for the preparation of the regulation that concerns me regarding the amendment of the Ombudsman Act that I had proposed.246 In my letter, I proposed the following amendments to be made to the Ombudsman Act: 11.1.1. According to Note a), Article 20 of the OPCAT, in order to ensure that the NPM fulfils his mandate, the state ensures access to “all information concerning the number of persons deprived of their liberty in places of detention as defined in article 4, as well as the number of places and their location”. Unfortunately, neither the Ombudsman Act nor any other law regulates at what intervals, in what form and within what deadline the government bodies concerned should meet their data supply obligations defined in Article 4 of the OPCAT. In lack of statutory provisions, it has been the practice of the recent years that the NPM asked the heads of the government bodies concerned in a letter to make available the data concerning the places 244 245 246 SPT visit to Hungary between March 21 and 30, 2017: conclusions and recommendations for the National Preventive Mechanism (CAT/OP/HUN/R.2), Section 19. Pursuant to Article 6 (1) of the Fundamental Law of Hungary, “The President of the Republic, the Government, any parliamentary committee or any Member of the National Assembly may initiate Acts.” The letter to the Minister of Justice was put on file in my Office under number AJB-4496/1/2018.